Yesterday, the Internet Corporation for Assigned Names and Numbers (ICANN) opened a Public Comment proceeding to receive input on the final policy recommendations of the Generic Names Supporting Organization (GNSO) Expedited Policy Development Process EPDP on the Temporary Specification for gTLD Registration Data – Phase 2A. Specifically, this proceeding is seeking input on a set of final recommendations that relate to two topics: 1) the differentiation of legal vs. natural persons' registration data, and 2) the feasibility of unique contacts to have a uniform anonymized email address.
Link to Public Comment Proceeding:
Open for Submissions Date:
Tuesday, 23 November 2021
Closed for Submissions Date:
Thursday, 13 January 2022
What We Need your Input On:
The ICANN Board will soon consider the EPDP Phase 2A Final Report, which includes four policy recommendations. Prior to the Board's consideration of this Final Report, ICANN org is seeking input on the EPDP Phase 2A recommendations, which relate to the topics of 1) the differentiation of legal vs. natural persons' registration data, and 2) the feasibility of unique contacts to have a uniform anonymized email address.
An abbreviated version of the four recommendations is provided below:
- A field or fields MUST be created to facilitate differentiation between legal and natural person registration data and/or if that registration data contains personal or non-personal data.
- Contracted Parties who choose to differentiate based on person type SHOULD follow the guidance included in the report.
- If a GDPR Code of Conduct is developed, the guidance to facilitate differentiation between legal and natural person data SHOULD be considered within ICANN by the relevant controllers and processors.
- Contracted Parties who choose to publish a registrant-based or registration-based email address in the publicly accessible RDDS should evaluate the legal guidance obtained by the EPDP Team on this topic.
On 17 May 2018, the ICANN Board approved the Temporary Specification for generic top-level domain (gTLD) Registration Data to allow contracted parties to comply with existing ICANN contractual requirements while also complying with the European Union's General Data Protection Regulation (GDPR). This ICANN Board action triggered the GNSO Council initiation of an expedited policy development process (EPDP) on 19 July 2018. The EPDP was conducted in two phases: Phase 1 was chartered to confirm, or not, the Temporary Specification by 25 May 2019; Phase 2 was chartered to discuss, among other elements, a new system proposed to centrally handle requests for nonpublic registration data, the System for Standardized Access/Disclosure (SSAD).
The GNSO Council adopted the Final Report for Phase 2 during its meeting on 24 September 2020; however, in response to a request from some EPDP Team members, the GNSO Council asked the EPDP Team to continue work on two topics: 1) the differentiation of legal vs. natural persons' registration data, and 2) the feasibility of unique contacts to have a uniform anonymized email address. These two topics constituted the focus of Phase 2A.
The GNSO Council approved the Phase 2A Final Report on 27 October 2021.
Following this Public Comment proceeding, the ICANN Board is expected to act on the EPDP Phase 2A policy recommendations.